THE COMPANY

Global Disclosure Policy

Guy Carpenter is committed to providing our clients with the most professional service in the reinsurance industry. We believe transparency enables our clients to make more informed decisions regarding their reinsurance programs. We have, therefore, formulated specific policies and procedures to support full disclosure for clients with regard to treaty and facultative reinsurance transactions on a worldwide basis. This Global Disclosure Doctrine addresses all reinsurance placed by Guy Carpenter and accounts for differences in business practices and customs that exist in various regions of the world.

At Guy Carpenter, our brokers seek to make reinsurance placements that are in the best interests of our clients, based on our discussions with each client and our decades of experience in the reinsurance market. The factors we believe are relevant to consider with regard to placement include not only price and coverage terms but also the financial strength of the reinsurer(s), their commitment to continuing to provide this type of reinsurance for more than the immediate term, their responsiveness in paying reinsurance claims, their other services provided and other factors that the client may consider important in the particular circumstances.

Treaty Reinsurance Disclosure Policy

In order to ensure transparency with regard to treaty reinsurance transactions, Guy Carpenter has implemented the following procedures:

When Guy Carpenter is appointed broker of record, we will disclose to our clients the compensation that we anticipate receiving for the services to be provided on the client's behalf by providing a copy of this Global Disclosure Doctrine.

Prior to subsequent renewals of reinsurance contracts, Guy Carpenter will review with our clients our expected compensation based on standard rates of brokerage.

While consistency in the terms of placements and total premiums charged the client often is considered by our clients and us to be preferable, that is not always achievable. We will discuss with our clients how we should proceed with any market proposals.

Consistent with prior practices, a summary of all formal and final quotes and declinations received from markets will be sent to clients before binding.

Brokerage for each reinsurance transaction will be listed on the Cover Note (or equivalent) for all treaty business.

Rates of Brokerage - Treaty Reinsurance

Guy Carpenter's longstanding practice is to charge rates of brokerage consistent with industry custom and practice. Following are the rates of brokerage that apply to the majority of business placed by Guy Carpenter. These rates are guidelines and are generally the norm in the marketplace, but they can vary depending on the details of a particular placement.

For excess of loss placements, Guy Carpenter generally receives brokerage of between 5 percent and 10 percent of contract premium.

When excess of loss placements are made with a wholesale broker, an additional 5 percent brokerage may be earned by the wholesale broker. A Guy Carpenter-affiliated broker is often used on these placements.

In some markets, Guy Carpenter receives brokerage of up to 5 percent on reinstatement premiums.

On some placements, a stated margin is part of the premium. In such cases, Guy Carpenter generally receives 20 percent of that portion of the premium as compensation.

Facultative Reinsurance Disclosure Policy

Facultative reinsurance business varies in complexity, structure and variety of solutions offered to our clients, further complicated by line of business and geographic region. There is, therefore, no standard brokerage rate that can be applied to all facultative placements.

In order to ensure transparency throughout a facultative reinsurance transaction, Guy Carpenter has implemented the following procedures:

Guy Carpenter will present all new clients with a copy of this Global Disclosure Doctrine when we begin working on new facultative business, which contains a range of brokerage rates applicable to facultative reinsurance transactions in the regions of the world in which we operate.

While consistency in the terms of placements and total premiums charged the client often is considered by our clients and us to be preferable, that is not always achievable. We will discuss with our clients how we should proceed with any market proposals.

Guy Carpenter will not disclose underwriting, pricing information or other program information to any party not directly involved in the reinsurance placement (e.g., retail brokers) without approval of our clients.

Rates of Brokerage - Facultative Reinsurance

As with treaty reinsurance placements, Guy Carpenter's practice is to charge rates of brokerage consistent with industry custom and usage within a geographic region. Due to the fast-paced, transactional nature of facultative placements, however, and the limited lead time clients typically have to make the purchase decision, brokerage rates for a given transaction may not be determined until after the placement is complete.

Guy Carpenter supports transparency with regard to disclosure of brokerage rates and sets forth below the rates of brokerage that apply for the majority of facultative business we place:

In all geographic regions of the world, and for all lines of business except United States Casualty Facultative business, the standard rate that Guy Carpenter will earn is 15 percent of ceded reinsurance premium.

For United States Casualty Facultative business, the standard rate Guy Carpenter will earn is 10 percent of ceded reinsurance premium.

Should Guy Carpenter earn less than the above rates on a particular placement, we will not report it to clients. Should we earn more than the above rates on a given placement, however, we will disclose to the client the actual brokerage rate to be earned as soon as practical.

Any upward deviation on the above brokerage rates from an individual market on a placement, in a quote or at binding, will be disclosed to the client.

On some facultative placements, a local or wholesale broker may be used to access a particular market. An additional 5 percent to 10 percent brokerage will be earned on such transactions. A Guy Carpenter affiliated broker is often used on these placements.

Should a particular placement entitle Guy Carpenter, as a whole, to earn more than 20 percent in total compensation, this will also be disclosed to the client.

Additional Disclosures

As is well known and commonplace among intermediaries in our industry, markets for our clients' placements are often themselves clients of Guy Carpenter on other, unrelated placements. On those occasions where Guy Carpenter has at the time been appointed intermediary for a market retroceding some or all of the risk initially ceded to that market in the original reinsurance placement by Guy Carpenter, we will disclose this transaction to our original client.

A listing of those insurance or reinsurance companies in which our parent company, Marsh & McLennan Companies, Inc. (MMC), has an equity interest is available in the "Related Links" box below.

In order to provide further financial information and comply with certain regulatory requirements, Guy Carpenter's annual financial results are available in our consolidated corporate group Annual Statement, which is available at www.mmc.com, under the "Investors" link.

In addition to traditional reinsurance intermediary services, Guy Carpenter also provides other "non-traditional" reinsurance related services for which we receive fees. Revenue from these activities represents a small portion of Guy Carpenter's annual revenue. Additional information on these activities is available upon request.

Interest Income

In accordance with common practice and general custom and usage within the reinsurance business, Guy Carpenter retains interest earned on fiduciary funds passing through our systems in the normal course of business. This has always been our practice, and such interest is viewed as part of our overall compensation. Thus, providing Guy Carpenter with an order to place reinsurance is considered consent to retain this interest income. When requested by our clients, however, we will obtain written agreement to retain such interest income.

Trade Sanctions Policy

Across the globe, there are a growing number of trade sanctions laws (adopted by the EU, US, UN, and other countries) that can affect the placement of reinsurance and the payment of premiums and claims. These laws are very complicated and, often, can change during and after the policy period. For certain classes of business, it is becoming increasingly common for reinsurers to impose a sanctions exclusion clause, which makes it clear that the reinsurance cannot respond where coverage or payment of a claim would expose reinsurers to sanctions penalties.

As an intermediary, we also have to safeguard our position to ensure we comply with the laws and regulations that apply to us. Accordingly, in the event that any particular risk under any reinsurance agreement we place on your behalf may not comply with the sanctions laws applicable to Guy Carpenter, we will not be able to undertake any role relating to that risk (including placement, processing, administration, or any communications relating to such risk). In that event, we will of course inform you of the position as soon as possible.

If you have any questions or concerns, please contact the Guy Carpenter Legal or Risk & Compliance Departments.

This Global Disclosure Doctrine is provided by Guy Carpenter & Company, LLC for general information only. The information contained herein consists of guidelines which do not affect the contractual terms and conditions governing a particular reinsurance transaction.

Compensation Disclosure and Financial Condition

Guy Carpenter & Company, LLC strives for transparency in all areas for its clients. Upon request, Guy carpenter will provide a report showing the annual compensation it earned in the previous year on a client's business.

Guy Carpenter also reminds clients that information regarding our financial condition is available as part of the consolidated financial statement of our corporate group, Marsh & McLennan Companies, Inc., in accordance with certain regulatory requirements. Annual statements for Marsh & McLennan Companies, Inc. are available by visiting www.mmc.com and clicking on the "Investors" link. Please note that Guy Carpenter makes these reports available in this manner in lieu of physical mailings.

If you wish to receive a compensation report, or have any questions on Guy Carpenter's consolidated financial statements, please contact Kelly Granatek, Chief Compliance Officer, Americas (Kelly.M.Granatek@guycarp.com or +1.860.550.8278).